Presidential Executive Order: Promoting Access to Mortgage Credit

An Executive Order (EO) issued Friday is intended to expand homeownership opportunities by directing federal housing agencies and financial regulators to take actions that streamline and reduce barriers to homeownership.

The Order tasks agencies such as the Department of the Treasury, Department of Housing and Urban Development (HUD), Federal Housing Finance Agency (FHFA), Consumer Financial Protection Bureau (CFPB), and federal banking regulators (NCUA, Federal Reserve, FDIC, and OCC) with reviewing existing rules, underwriting standards, capital requirements, and servicing obligations to ensure they are not unduly constraining lending. Many of the most immediate and achievable actions fall within existing regulatory authority, including updating agency guidance, clarifying underwriting flexibility, streamlining appraisal and servicing requirements, and aligning supervisory expectations to reduce uncertainty for lenders.

In contrast, more structural changes such as modifications to statutory capital frameworks, GSE mandates, or changes to Qualified Mortgage (QM) would likely require Congressional action. As a result, the near-term impact of the Executive Order will likely be driven by interagency coordination and targeted regulatory adjustments that can be implemented without legislation, offering the most expedient path to expanding access to mortgage credit.

GoWest Credit Union Association is reviewing this order to assess its potential impact on credit unions and the broader housing finance system. As part of this review, GoWest will evaluate which elements could be addressed through regulatory or supervisory action versus those that may require statutory changes. GoWest will also engage with member credit unions to gather feedback, identify operational and compliance implications, and inform advocacy priorities as we work with agencies and members of Congress to operationalize this Executive Order.

Summary of the Order

Purpose and Policy Direction

The order seeks to expand access to affordable mortgage credit by reducing regulatory burdens that have discouraged community banks and smaller institutions from participating in mortgage lending. It emphasizes tailoring rules to institutions under $100 billion in assets, modernizing mortgage origination and servicing, promoting competition across lender types, and strengthening housing‑finance liquidity—particularly for rural, low‑ and moderate‑income borrowers.

Mortgage Origination, ATR, and QM Reform

The order directs the CFPB and prudential regulators to consider changes that would simplify and tailor Ability‑to‑Repay (ATR) and Qualified Mortgage (QM) requirements for smaller institutions. Key concepts include broader QM safe harbors for portfolio loans, replacing rigid TRID timing rules with a materiality‑based standard, adjusting QM points‑and‑fees caps for small loans, modernizing rescission rights (including digital processes), and streamlining refinancing requirements. Supervisory guidance would shift examiner focus away from technical errors and toward prudent underwriting and borrower outcomes, with a correction‑first approach for good‑faith compliance issues.

HMDA Modernization

The order calls for raising HMDA reporting exemption thresholds for smaller institutions, excluding inquiries from reportable data, and reducing privacy risks and compliance costs associated with complex HMDA reporting systems and training requirements.

Capital, Liquidity, and FHLB Alignment

Regulators are encouraged to better align capital and liquidity requirements with actual mortgage credit risk, particularly for portfolio loans, mortgage servicing assets, and warehouse lending. The order also emphasizes modernizing Federal Home Loan Bank collateral processes, expanding access to longer‑term advances, creating targeted liquidity programs for entry‑level and owner‑occupied housing, and improving the speed and efficiency of collateral valuation and boarding.

Construction and Housing Supply

Supervisory guidance would be revised to exclude one‑to‑four‑family residential construction and development lending from commercial real estate concentration limits and to support responsible construction lending by community banks, with the goal of increasing housing supply.

Appraisal Modernization

Agencies are directed to explore the expanded use of alternative valuation methods, including desktop and hybrid appraisals and AI‑based tools, simplified appraiser qualification requirements, reduced appraisal requirements for low‑risk transactions, and clearer appraisal timelines. It also seeks better alignment of appraisal standards across FHA and VA programs and greater flexibility for post‑closing repairs.

Digital Mortgage Modernization

Federal housing and lending agencies are directed to eliminate unnecessary wet‑signature requirements, standardize acceptance of e‑signatures, e‑notes, and remote online notarization, and promote uniform digital mortgage standards.

Servicing, Supervision, and Enforcement

The order aims to provide greater supervisory certainty for portfolio mortgage servicing by smaller institutions. It encourages simplified servicing requirements, cure‑first treatment for good‑faith errors, exemptions from complex servicing rules, and enforcement policies that reserve civil penalties for willful or reckless violations while allowing time for self‑identification and remediation.

Licensing and General Provisions

Finally, the order calls for eliminating duplicative or unnecessary mortgage loan officer licensing or registration requirements for smaller banks. It reiterates that implementation is subject to existing legal authority, appropriations, and does not create enforceable rights.

GoWest will continue to engage on these developments and provide updates as additional information becomes available. We welcome and encourage member feedback. Please reach out to John Trull or Erin Hall with any questions or comments.

Posted in Advocacy on the Move, Federal Advocacy, Regulatory Advocacy.